Capstone sets the standard for creating and adhering to a set of compliance principles that protects our clients and our business. Though we believe a system of clear rules, consistent supervision and regular education are important elements of a good compliance plan, we do not believe these guidelines are a substitute for creating a strong culture of ethical behavior.

Capstone Compliance Highlights:

Bi-annual mandatory compliance training (conducted by leading law firm K&L Gates) with a specific focus on issues related to political intelligence

A compliance script that is read before every interaction with government employees that asks them not to reveal any confidential information

A supervisory process that ensures that three managers sign-off that specific procedures are followed prior to each note being published. Process specifically designed to prevent MNPI from being disseminated

Strict procedures for the hiring and compensation of outside consultants

Capstone does not operate an expert network business model. Our core product is the analysis of our investment professionals. We do hire experts from time to time, but these interactions are strictly controlled. Capstone employees are prohibited from compensating government officials (federal, state, local or foreign) in any way for meetings, conversations or other interactions. Capstone employees are prohibited from compensating any person who has been a government official (federal, state, local or foreign) within the last six months of when the payment is made. Capstone employees are prohibited from compensating any current employees of a publicly listed company or any person who has been an employee of a publicly listed company within the last 12 months of when the payment is made. Capstone employees must clear compensation for other sources (lawyers, outside experts, etc.) with the chief compliance officer.

- Capstone LLC -

Washington DC

-Capstone Research Limited-

London

The investment adviser or investment adviser representative in question may only transact business in this state if first licensed, excluded, or exempted from the state investment adviser or investment adviser representative licensing requirements; and individualized responses to persons in this state by the investment adviser or investment adviser representative that involve either effecting or attempting to effect transactions in securities, or rendering of personalized investment advice for compensation, will not be made without compliance with the state investment adviser or investment adviser representative licensing requirements, or an applicable exemption or exclusion.